That is much stronger and more likely to succeed then your last
(admittedly shorthand) argument that blocking a delivery method is not
the same as blocking content. :-)
El jun. 10, 2015 5:44 PM, Josh Reynolds <[email protected]> escribió:
A person engaged in the provision of broadband Internet access
service, insofar as such person is so engaged, shall not block lawful
content, applications, services, or nonharmful devices, subject to
reasonable network management.
A person engaged in the provision of broadband Internet access
service, insofar as such person is so engaged, shall not impair or
degrade lawful Internet traffic on the basis of Internet content,
application, or service, or use of a non-harmful device, subject to
reasonable network management.
source: https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-24A1.pdf
"Your honor/<insert title>, in our Acceptable Use Policy that each
customer signs, in accordance with the rules laid down by the FCC, we
very clearly detail any and all network management practices that we
use while stating the reason for such practices. As we run a
fixed-wireless network, P2P transmissions have a very detrimental
effect on wireless networking equipment - it affects all users on that
node (and often other nodes) and impacts our ability to provide
consistent service that individuals and businesses pay for. We have
very little recourse in the matter. We can either block this singular
type of traffic - not the content, but the delivery method - in
accordance with the reasonable network management clauses laid down in
the FCC's rulings, or we can allow a singular user to impact the
ability of several dozen or several hundred people. It is our belief
that the FCC would not be so heavy handed and shortsighted as to force
providers to allow a very specific type at the detriment of so many.
We encourage the manufacturers of fixed wireless equipment to "harden"
and redesign their equipment when and where necessary to allow us to
unblock this singular type of traffic, so that we may open this back
up. In addition, we have had no complaints over _X_ years due to this
traffic limitation [obviously until this time]. Had an individual or
business questioned our AUP or called to complain, we could have
suggested they tunnel their P2P traffic over any one of a number of
proxy or VPN services available for free or for a small fee on the
internet. This would allow them access to the content they requested,
still via P2P clients, without having a negative impact on other
subscribers."
... just a brief snippet :P
Josh Reynolds
CIO, SPITwSPOTS
www.spitwspots.com <http://www.spitwspots.com><http://www.spitwspots.com>
On 06/10/2015 02:05 PM, Ken Hohhof wrote:
It actually looks like I was totally wrong, you haven’t been able to
do it since this FCC Declaratory Ruling in 2008:
https://apps.fcc.gov/edocs_public/attachmatch/DOC-284286A1.pdf
From: Hass, Douglas A.<mailto:[email protected]>
Sent: Wednesday, June 10, 2015 4:54 PM
To: [email protected]<mailto:[email protected]>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz
I disagree that you could split hairs that way. Blocking a method has
the effect of blocking content, which is all that someone needs to show.
El jun. 10, 2015 4:52 PM, Josh Reynolds
<[email protected]><mailto:[email protected]> escribió:
You're a lawyer now? :)
For the record, blocking a delivery method != blocking content.
Josh Reynolds
CIO, SPITwSPOTS
www.spitwspots.com
<http://www.spitwspots.com><http://www.spitwspots.com>><http://www.spitwspots.com>
<%3E%3Chttp://www.spitwspots.com%3E>
On 06/10/2015 12:02 PM, Ken Hohhof wrote:
You are not allowed to block legal content. Period.
If you rate limit it, you could perhaps claim it is reasonable network
management, but “no throttling” is another of the 3 bright line rules.
Remember one of the 2 or 3 actual cases of “bad behavior” cited for
justifying all this was Comcast interfering with Bit Torrent back in
something like 2007, and they weren’t even outright blocking it.
As far as being sued, a customer could file a complaint with the FCC,
rather than pursuing civil damages, likely that is the way they would
go since all they have to do is fill in a form on the FCC website.
My guess is the FCC will be much more interested in pursuing
complaints from the likes of Netflix, Cogent and Level3 against the
likes of Comcast, Verizon and Time Warner. Unless you piss off John
Oliver. So it might just be like the BBB, they just send you the
complaint and let you figure out what to do with it. That reminds me,
I need to check if we are supposed to be registering a contact to
receive Open Internet Order complaints, that kind of rings a bell, but
maybe I’m confusing it with having a DC registered agent for CPNI
complaints if you file Form 499.
The other factor on your side is the customer might not want to
complain to the FCC if their reasons for using Bit Torrent are not
exactly legal or moral. And customers wanting to torrent legitimate
content, like maybe Linux ISOs, will probably just use another method
and not have a cow over it.
From: Josh
Reynolds<mailto:[email protected]><mailto:[email protected]>
Sent: Wednesday, June 10, 2015 2:46 PM
To:
[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz
I'll say this again: After consulting with no less than 3 legal firms
who specialize in communications/fcc law, we are in the clear. I'm not
going to get into a debate about the legality of this because (A) I'm
not a lawyer and (B) neither are you. We have been told that
subscribers agree to the restrictions on our network when they sign a
contract. The language is the same used for commercial services.
Yes, the restriction applies to all torrent traffic.
Josh Reynolds
CIO, SPITwSPOTS
www.spitwspots.com
<http://www.spitwspots.com><http://www.spitwspots.com>><http://www.spitwspots.com>
<%3E%3Chttp://www.spitwspots.com%3E>
On 06/10/2015 11:37 AM, Josh Luthman wrote:
IMO your only concern should be getting sued. Anyone that's torrenting
stuff probably doesn't have the money for a lawyer to do that.
Do you do any CIR connections for businesses? Do you block them?
Josh Luthman
Office: 937-552-2340
Direct: 937-552-2343
1100 Wayne St
Suite 1337 3
Troy, OH 45373
On Wed, Jun 10, 2015 at 3:35 PM, Josh Reynolds
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
wrote:
And after that based on the legal advice we have received from no less
than 3 Communications Lawyers
Josh Reynolds
CIO, SPITwSPOTS
www.spitwspots.com
<http://www.spitwspots.com><http://www.spitwspots.com>><http://www.spitwspots.com>
<%3E%3Chttp://www.spitwspots.com%3E>
On 06/10/2015 09:41 AM, Ken Hohhof wrote:
And you can legally do it until this Friday.
From: Josh
Reynolds<mailto:[email protected]><mailto:[email protected]>
Sent: Wednesday, June 10, 2015 12:10 PM
To:
[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz
We have been blocking torrents as a network protection measure for
over 6 years using various DPI and behavioral detection systems, and
its in our AUP. We have never lost a customer or even had a complaint
because of it.
On Jun 10, 2015 4:56 AM, Mathew Howard mailto:[email protected] wrote:
Agreed. I don't even want to think about how many calls we would have
to deal with if blocked VPNs... and torrents for that matter.
On Wed, Jun 10, 2015 at 7:10 AM, Mike Hammett
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
wrote:
Yes and blindly killing things is a terrible practice.
-----
Mike Hammett
Intelligent Computing Solutions
http://www.ics-il.com
[http://www.ics-il.com/images/fbicon.png]<https://www.facebook.com/ICSIL><https://www.facebook.com/ICSIL>[http://www.ics-il.com/images/googleicon.png]<https://plus.google.com/+IntelligentComputingSolutionsDeKalb><https://plus.google.com/+IntelligentComputingSolutionsDeKalb>[http://www.ics-il.com/images/linkedinicon.png]<https://www.linkedin.com/company/intelligent-computing-solutions><https://www.linkedin.com/company/intelligent-computing-solutions>[http://www.ics-il.com/images/twittericon.png]<https://twitter.com/ICSIL><https://twitter.com/ICSIL>
Midwest Internet Exchange
http://www.midwest-ix.com
[http://www.ics-il.com/images/fbicon.png]<https://www.facebook.com/mdwestix><https://www.facebook.com/mdwestix>[http://www.ics-il.com/images/linkedinicon.png]<https://www.linkedin.com/company/midwest-internet-exchange><https://www.linkedin.com/company/midwest-internet-exchange>[http://www.ics-il.com/images/twittericon.png]<https://twitter.com/mdwestix><https://twitter.com/mdwestix>
________________________________
From: "Paul McCall"
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
To:
[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>
Sent: Tuesday, June 9, 2015 11:12:43 PM
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz
Rory, how do you “kill torrents”? technically,
And, aren’t there a lot o legitimate programs that use torrents as the
distribution method?
From: Af
[mailto:[email protected]<mailto:[email protected]><mailto:[email protected]>]
On Behalf Of Rory Conaway
Sent: Monday, June 08, 2015 3:54 PM
To:
[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz
If you have file sharers on there for example, I’ve seen XM radios
drop to 10Mbps or less (another reason we kill torrents). If you watch
the modulation levels when that happens, you will also see them drop
as the CPU load goes up.
Rory
From: Af
[mailto:[email protected]<mailto:[email protected]><mailto:[email protected]>]
On Behalf Of Josh Luthman
Sent: Monday, June 08, 2015 12:46 PM
To:
[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz
PS in the run queue? That certainly isn't load, there's no way an XM
radio can do 20+.
Josh Luthman
Office: 937-552-2340
Direct: 937-552-2343
1100 Wayne St
Suite 1337
Troy, OH 45373
On Mon, Jun 8, 2015 at 3:41 PM, Bill Prince
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
wrote:
I'm with Rory. It depends a lot on the traffic, and and what role it
may be playing (backhaul, AP, or SM). This is just a 1 day snapshot of
one in SM role.
[X]
bp
<part15sbs{at}gmail{dot}com>
On 6/8/2015 12:34 PM, Josh Luthman wrote:
SSH into every single AP and it says 0.00 or 0.01. I used to graph it
way back (maybe 5.3 days?) and I never saw it deviate. This is
definitely all XM gear.
Josh Luthman
Office: 937-552-2340
Direct: 937-552-2343
1100 Wayne St
Suite 1337
Troy, OH 45373
On Mon, Jun 8, 2015 at 3:27 PM, Rory Conaway
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
wrote:
I would have to se your data, mine does not support that.
Sent from fromm phone where I type with a single digit so please
excuse shortcuts or typos.
Rory Conaway
Triad Wireless
-------- Original message --------
From: Josh Luthman
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
Date: 06/08/2015 3:26 PM (GMT-05:00)
To:
[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz
If that was the case why are the loads of every radio 0.01 or less?
Josh Luthman
Office: 937-552-2340
Direct: 937-552-2343
1100 Wayne St
Suite 1337
Troy, OH 45373
On Mon, Jun 8, 2015 at 3:22 PM, Rory Conaway
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
wrote:
To prove my point further, if you do throughput testing with Ubiquity
in ptmp mode, you will find with xm radios, cpu load affects
modulation levels. I haven't tested xw radios yet but I believe the
threshold is just higher and probably justifies 30mhz but it's going
to be close.
Sent from fromm phone where I type with a single digit so please
excuse shortcuts or typos.
Rory Conaway
Triad Wireless
-------- Original message --------
From: Rory Conaway
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
Date: 06/08/2015 3:16 PM (GMT-05:00)
To:
[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz
The pps and cpu load absolutely is another variable you need to take
into acount, especially with 400 and 526mhz atheros processors that
are also running polling. Ignore it as part of your overall strategy
and you could be wasting spectrum. If your ap never exceeds 80mbps,
why do you want 30mhz channels. Sarcasm aside, does that help you
understand my point.
Sent from fromm phone where I type with a single digit so please
excuse shortcuts or typos.
Rory Conaway
Triad Wireless
-------- Original message --------
From: Josh Reynolds
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
Date: 06/08/2015 2:17 PM (GMT-05:00)
To:
[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz
I think we are having two different conversations, and I have no idea
what you are talking about right now.
What we were discussing has to do with channel sizes, epmp, and
ubiquiti. In particular, why UBNT 40mhz isn't any better than 30mhz in
terms of efficiency.
This part of the discussion has nothing at all to do with any theories
on PPS you may have, other than those you have tried to inject into
this discussion.
On Jun 8, 2015 10:07 AM, Rory Conaway
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
wrote:
Excopt that as was mentioned before, the s/n ratio goes down and if
you aren't hitting the limits of the physical layer in 20MHz, why do it?
Sent from fromm phone where I type with a single digit so please
excuse shortcuts or typos.
Rory Conaway
Triad Wireless
-------- Original message --------
From: Josh Reynolds
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
Date: 06/08/2015 12:43 PM (GMT-05:00)
To:
[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz
I can assure you that on radios connected in a ptp config or small
ptmp, that you will see more throughput on the 30mhz channel given a
noise floor of -97 and signals in the mid -50s, even with nothing
connected on the other side of the radios.
Its an efficiency issue.
On Jun 8, 2015 8:13 AM, Mathew Howard
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
wrote:
I kind of does, the way I understood it, that bottleneck limited you
from really being able to do anything beyond what a 30mhz channel
could support.
Now that I think about it, I have seen 40mhz perform better than
30mhz... but yes, that was because of RF problems, and neither one was
doing anything close to what it would with a good link.
On Mon, Jun 8, 2015 at 11:09 AM, Josh Reynolds
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
wrote:
That is a bottleneck in the system, but not relevant as far as this
discussion goes. That has nothing to do with the 30/40MHz channel
efficiency per say.
On Jun 8, 2015 8:03 AM, Rory Conaway
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
wrote:
The limitation on the older xm radios was pps. When you added a lot of
small packets and airmax, you could drop down to as low as 40Mbps. In
the real world in ptmp mode. We planned for 50mhz per AP with
eveything g taken into account.
Sent from fromm phone where I type with a single digit so please
excuse shortcuts or typos.
Rory Conaway
Triad Wireless
-------- Original message --------
From: Josh Reynolds
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
Date: 06/08/2015 11:59 AM (GMT-05:00)
To:
[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz
This. Thought it was pretty obvious but I guess I assumed too much out
of some on this list ;)
On Jun 8, 2015 7:33 AM, Jeremy
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
wrote:
I think he is talking about using 40MHz channels on the older M
series, that didn't have gig ports. It was my understanding that the
processor would get taxed as well on a 40MHz channel, making 30MHz
actually work better.
On Mon, Jun 8, 2015 at 9:24 AM, Josh Luthman
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
wrote:
Ubnt and epmp have gig ports.
Josh Luthman
Office: 937-552-2340
Direct: 937-552-2343
1100 Wayne St
Suite 1337
Troy, OH 45373
On Jun 8, 2015 11:20 AM, "Josh Reynolds"
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
wrote:
I don't know how epmp does it.
For UBNT, a 30mhz channel is just a "fat" 20mhz channel in the atheros
chip. Single operation. For a 40mhz channel, it's really two 20s,
meaning radio operations are ran twice. Loss in efficiency, also
marred by the lack of gigabit port.
On Jun 8, 2015 7:13 AM, Mathew Howard
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
wrote:
I've never seeing much difference in performance on the ubnt M series
between 30mhz and 40mhz channels, so yes, I would say that is true...
but I'm not sure how much applies to ePMP - they do have a much a
faster processor and on a software level they are very different.
So far, I have been running all of our ePMP APs on 20mhz channels and
PTP links on 40mhz or 20mhz, depending on how much capacity they need.
I haven't really seen much need to go down to 10mhz channels with ePMP.
On Mon, Jun 8, 2015 at 8:43 AM, Shayne Lebrun
<[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>>
wrote:
I seem to recall that with the M series, at least, a 30 mhz channel
works 'better' than a 40 because the 40 is really two 20 mhz channels
bonded together, where a 30 mhz channel is a 30 mhz channel.
-----Original Message-----
From: Af
[mailto:[email protected]<mailto:[email protected]><mailto:[email protected]>]
On Behalf Of Rory Conaway
Sent: Saturday, June 6, 2015 8:32 PM
To:
[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>
Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz
I'm not that familiar with the ePMP's yet but I can tell you some
things that we saw with Ubiquiti. One is that channel width does not
scale with bandwidth that that Atheros chipset. For example, 40MHz
channels rarely hit their theoretical maximum due to a variety of
factors, noise, lower s/n, processor limitations, etc... Second, 20MHz
channels seem to be the sweet spot but even with GPS sync, you have to
deal with reflections. Third, 10MHz channels have more overhead as a
percentage of total capacity and don't handle a lot of users well
(above 40 for example with the older 400MHz chipsets. I'm starting to
deploy XW radios with the 520MHz processors but everything is 20MHz
now so I don't have a comparison). We did see peaks of 32Mbps with
some customers on 10MHz channels but that's non-peak times. In peak
times, we were seeing 8Mbps when more users were online.
Rory
-----Original Message-----
From: Af
[mailto:[email protected]<mailto:[email protected]><mailto:[email protected]>]
On Behalf Of Craig House
Sent: Saturday, June 06, 2015 5:20 PM
To:
[email protected]<mailto:[email protected]><mailto:[email protected]><mailto:[email protected]>
Subject: [AFMUG] EPMP 10 mhz vs 20mhz
We have deployed 6 towers to begin our new EPMP network and 4 of those
towers have a full cluster of 2.4 90 degree EPMP sectors. They are
configured with ACS turned off now because in several cases they all
ended up on the same or very close to the same channel. I have Front
back designations and non overlapping channels set up on all towers. I
have tried 40 mhz 20 mhz and now 10mhz channels and while the customer
stability has gotten better the more I play with settings I have kind
of hit a point I dont know what else to try. I have some that the
uplink quality will vary wildly from 100% to 0%. Most have gotten
better since I went to a 10mhz channel. Most of the customers get 12MB
-30mb down in the wireless link test but the uplinks are as bad as
.17. What is the cause of this poor uplink quality? Is it
interfernece? My one 5ghz AP does not have this problem but even with
noise many of these customers have -50 signals and oddly enough the
ones with the great signals seem to be the ones that have the poorest
link tests on the up link side. I also have customes with -65 or -72
signals that get 5MB up on the same sectors? Im scratching my head a
bit on what the fix is for this? Should I leave ACS on and change
everything to 10mhz channels? Will a full cluster with ACS on work all
on the same channel?
I'm used to FSK where you pick your channel and any channels that are
adjacent will cause problems with connected SM's. So am I just
applying old knowledge to a technology that it doesn't apply to?
Craig
Douglas A. Hass
Associate
312.786.6502
[email protected]<mailto:[email protected]>
Franczek Radelet P.C.
300 South Wacker Drive
Suite 3400
Chicago, IL 60606
312.986.0300 - Main
312.986.9192 - Fax
www.franczek.com <http://www.franczek.com><http://www.franczek.com>
www.wagehourinsights.com
<http://www.wagehourinsights.com><http://www.wagehourinsights.com>
Connect with me:
[linkedin]<http://linkedin.com/in/douglashass>
[twitter]<https://twitter.com/WageHourInsight>
Circular 230 Disclosure: Under requirements imposed by the Internal
Revenue Service, we inform you that, unless specifically stated
otherwise, any federal tax advice contained in this communication
(including any attachments) is not intended or written to be used, and
cannot be used, for the purposes of (i) avoiding penalties under the
Internal Revenue Code or (ii) promoting, marketing or recommending to
another party any transaction or tax-related matter herein.
________________________________
For more information about Franczek Radelet P.C., please visit
franczek.com. The information contained in this e-mail message or any
attachment may be confidential and/or privileged, and is intended only
for the use of the named recipient. If you are not the named recipient
of this message, you are hereby notified that any dissemination,
distribution, or copying of this message or any attachment thereto, is
strictly prohibited. If you have received this message in error,
please contact the sender and delete all copies.
________________________________
Franczek Radelet is committed to sustainability - please consider the
environment before printing this email
